Protective and substantive additions must be adjudicated together where related bank account proceedings remain pending.

Where additions arise from the same bank account and related transactions, the Tribunal held that substantive and protective assessments should be considered together because the issue in the connected proceeding was still pending. As the corresponding appeal had not yet been decided, the appellate order in the assessee's case was premature. The matter was therefore set aside for fresh adjudication by the first appellate authority after joint consideration of both proceedings, and the appeal was allowed for statistical purposes.

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Issues: Whether the matter required de novo adjudication because the substantive and protective additions arising out of the same bank account and related transactions had not been decided simultaneously.

Analysis: The Tribunal noted that the addition in the assessee's hands was intertwined with the corresponding substantive proceedings in the hands of the account holder. Since the connected appeal had not yet been decided, the appellate order on the assessee's appeal was considered premature. In such circumstances, the proper course was to set aside the matter and require fresh adjudication after considering both proceedings together.

Conclusion: The matter was remanded to the first appellate authority for de novo adjudication, and the assessee's appeal was allowed for statistical purposes.

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